Top 10 False Claims Act Recoveries in 2025

By the Constantine Cannon Whistleblower Team

As we reported last month in our post on the Department of Justice (DOJ) 2025 False Claims Act roundup, last year was another record year for False Claims Act recoveries.  In fact, the $6.9 billion the Government recovered in 2025 is the largest single-year haul ever under the statute.  As usual, the majority of that amount — more than $5.3 billion — came from actions originated by whistleblowers under the qui tam provisions of the statute.  This brings the total tally of False Claims Act recoveries to more than $85 billion since 1986, with roughly $61 billion of that amount flowing from whistleblower actions.

In terms of the primary areas of fraud that were the subject of last year’s False Claims Act recoveries, DOJ highlighted three — healthcare fraud,  procurement fraud, and customs fraud.  As we previously noted, DOJ has traditionally treated each of these areas as top enforcement priorities and the Trump Administration appears to be staying that course.  Of these three areas, healthcare-related cases dominated last year, accounting for $5.7 billion of the $6.9 billion in recoveries.

As we do every year, we have compiled our listing of the year’s Top 10 False Claims Act recoveries.  Unsurprisingly, they closely track the overarching False Claims Act enforcement trends — 8 of them were originated by whistleblowers, 7 of them involved healthcare-related fraud, and the remaining 3 involved procurement or customs fraud.  Here is our Top-10 list, with a link to our original post describing the action and resulting settlement in more detail:

• • No. 1 – Apex Medical ($310M).  On December 12, DOJ announced that wound graft company Apex Medical and its husband-and-wife owners Alexandra Gehrke and Jeffrey King would collectively pay $310 million for violating the False Claims Act and Anti-Kickback statute by billing Medicare, TRICARE, and CHAMPVA for medically unnecessary wound grafts for elderly and terminally ill patients and resulting from illegal kickbacks.  In addition to this payout, Gehrke and King were sentenced to 15.5 years and 14 years in prison respectively, and to pay more than a billion dollars in forfeitures and restitution.  The False Claims Act allegations originated in a whistleblower lawsuit under the qui tam provisions of the statute.  DOJ did not identify the whistleblowers or the award they would receive from the proceeds of the Government’s recovery.

• • No. 2 – Walgreens ($300M).  On April 21, DOJ — together with the Drug Enforcement Administration and Health and Human Services Inspector General — announced that Walgreens would pay at least $300 million to settle DOJ charges of violating the False Claims Act and Controlled Substances Act through its filling of improper opioid prescriptions.  According to the Government, for years Walgreens pharmacies filled millions of unlawful prescriptions for opioids and other controlled substances despite “clear red flags” that the prescriptions lacked a legitimate medical purpose, or were issued outside the usual course of professional practice.  The allegations originated in a whistleblower lawsuit filed by former Walgreens employees under the qui tam provisions of the False Claims Act.  They collectively received an award of 17.25% of the Government’s recovery.

• • No. 3 –  Gilead ($202M).  On April 29, DOJ announced that Gilead Sciences agreed to pay $202 million to settle allegations of violating the False Claims Act and Anti-Kickback Statute by paying physicians to speak at or attend sham medical conferences to induce them to prescribe various Gilead HIV drugs.  The allegations originated in a whistleblower lawsuit filed under the qui tam provisions of the False Claims Act, but DOJ did not identify the whistleblowers involved or the award they would receive.

• • No. 4 – Q Link ($110M).  On July 28, DOJ announced that Florida-based telecommunications provider Q Link Wireless and its owner Issa Asad would pay roughly $110 million to settle criminal and civil charges of violating the False Claims Act by defrauding the FCC’s Lifeline Program designed to assist low-income consumers with their telecommunications needs.  According to the Government, Q Link and Asad orchestrated a scheme of enrolling Lifeline customers who neither needed nor used their phones, including customers who never even had activated phones.

• • No. 5 – Horizon ($100M).  On November 14, New Jersey Attorney General Matthew Platkin announced that Horizon Healthcare Services (known as Horizon Blue Cross Blue Shield of New Jersey) would pay $100 million to settle allegations of violating the New Jersey False Claims Act by overcharging the State on its contract to administer the State’s employee benefit programs.  It is New Jersey’s largest non-Medicaid False Claims Act settlement ever.  The State’s action originated from a lawsuit filed by six whistleblowers under the qui tam provisions of the New Jersey False Claims Act.  As part of the settlement, the State agreed to provide five of the whistleblowers — Kevin Lyons, Patrick Colligan, Mark Kovar, Mark Flores, and Vince Flores — a $12 million whistleblower award from the proceeds of the settlement.

• • No. 6 – Empire Pain Center ($63.8M).  On April 21, DOJ announced that two operators of New Jersey’s Empire Pain Center Holdings — Eric Karlewicz and Nicco Romanowski — would pay $63.8 million for violating the False Claims Act and Anti-Kickback Statute by billing Medicare for medically unnecessary body braces and other durable medical equipment (DME) and exchanging kickbacks with telemedicine companies, physicians, and DME suppliers to further the scheme.  In addition, Karlewicz and Romanowski were sentenced to 51 and 80 months in prison respectively, and ordered to forfeit close to $70 million.  The matter was originated by Robert Jackson Tyler Jr., under the whistleblower provisions of the False Claims Act.  DOJ did not disclose the amount of the award.

• • No. 7 – L3 Technologies ($62M).  On May 22, DOJ announced that Utah-based defense contractor L3 Technologies would pay $62 million to settle charges it violated the False Claims Act by overcharging the Department of Defense on various military contracts.  According to the Government, L3 did not comply with TINA (Truth in Negotiations Act) transparency requirements and inflated its cost and pricing data for labor, material, and other costs.

• • No. 8 – Biohaven ($60M).  On January 24, DOJ announced Pfizer subsidiary Biohaven Pharmaceutical Holding Company would pay roughly $60 million to settle allegations of violating the False Claims Act and Anti-Kickback Statute by paying kickbacks to induce prescriptions of Biohaven’s migraine medication Nurtec.  According to the Government, Biohaven provided healthcare professionals with paid speaking opportunities and expensive meals for programs with no educational benefit.  Pfizer terminated the Nurtec speaker programs after it acquired Biohaven.  The allegations originated in a whistleblower lawsuit filed by former Biohaven sales representative Patricia Frattasio, who received a whistleblower award of $8.4 million from the proceeds of the Government’s recovery.

• • No. 9 – Seoul Medical ($58.7M). On March 26, DOJ announced that California-based Seoul Medical Group and its subsidiary Advanced Medical Management would pay $58.7 million to settle allegations they violated the False Claims Act by inflating the risk scores for their Medicare Advantage patients to inflate their Medicare reimbursement.  The allegations originated in a whistleblower lawsuit but DOJ did not identify the whistleblower or the amount of the whistleblower award.

• • No. 10 – Ceratizit ($54.4M). On December 18, DOJ announced that North Carolina-based Ceratizit USA would pay $54.4 million to settle allegations it violated the False Claims Act by failing to pay duties it owed Customs and Border Protection on the products it imported from China.  The allegations originated in a whistleblower lawsuit filed by Mark Stover under the qui tam provisions of the False Claims Act.  He will receive a whistleblower award of roughly $9,750,000 from the proceeds of the Government’s recovery.

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Constantine Cannon whistleblower partner Marlene Koury found no real surprises in this past year’s Top-10 listing.  She said, “It reflects how healthcare, procurement, and customs fraud continue to account for the bulk of Government recoveries.”  “Even more importantly,” she added, “it shows how whistleblowers continue to play a critical role in the Government’s fraud enforcement regime.”  Koury stressed “that role is even more important these days with the resource constraints the Government has faced (and continues to face) at DOJ and its sister enforcement agencies.”

Constantine Cannon has substantial experience representing whistleblowers under the False Claims Act.  If you would like to learn about our various whistleblower successes or what it means to be a whistleblower under the False Claims Act, please do not hesitate to contact us.  We will connect you with an experienced member of our whistleblower team for a free and confidential consultation.  Maybe you will be the whistleblower who originates one of the next big Top-10 recoveries!

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